JUDGMENT :

J.B.PARDIWALA, J.

1. As the issues raised in all the captioned tax appeals are the same and the parties are also the same, those were heard analogously and are being disposed of by this common judgment.

2. This batch of Tax Appeals under Section 260A of the Income Tax Act, 1961 (for short “the Act, 1961”) is at the instance of the Revenue and are directed against the order passed by the Income Tax Appellate Tribunal, ‘C’ Bench, Ahmedabad, dated 30th July 2020 in the ITA Nos. 361/Ahd/2014, 1662/Ahd/2014, 829/Ahd/2017, 803/Ahd/2017, 91/Ahd/2014, 330/Ahd/2014, 2283/Ahd/2014, 752/Ahd/2017, 753/Ahd/2017 and 2321/Ahd/2017 respectively for the Assessment Years 2009-2010 to 2014-2015.

3. The Revenue has proposed the following substantial questions of law for the consideration of this Court:

In Tax Appeal No. 157 of 2020

“(A) Whether on the facts and in the circumstances of the case, the Appellate Tribunal is justified in negating the findings of the CIT(A) as well as the Assessing Officer denying the benefits of Sections 11 and 12 of the Act by invoking proviso to Section 2(15) r.w. Section 13(8) of the Act?

(C) Whether on the facts and in the circumstances of the case, the Appellate T